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Lynn Shapiro Snyder, an attorney with Epstein, Becker & Green PC in Washington, told Bloomberg BNA Aug. 14 there has been much discussion about payment for performance or outcomes. However, not all of these payment methods involve both a “carrot” if there are savings as well as a “stick,” or penalty, if there are losses, she said.

“The importance of CMS's most recent announcement is that the 360 organizations have now converted their payment method from carrot only to carrot and stick,” Shapiro Snyder said. “These 360 organizations and their many participating providers will need to coordinate care well in order to gain from the new payment method that will reward them financially if there are savings and good quality.” …

Some hospitals participating in the bundled payments initiative would be barred from participating in the CCJR program under participation requirements specified in the proposed rule, Yeung said.

“We urge everyone to consider commenting” Yeung said. “Providers should be commenting on this and other issues relevant to the CCJR model,” she told Bloomberg BNA.